Clause 1

Nusrat Ghani Excerpts

Monday 12th January 2026 Commons Chamber

[Dan Tomlinson]

This is the normal way that inheritance tax assets are taxed. There is not just APR and BPR, and the changes coming in in April; other assets are passed on through inheritance. We are applying the same treatment here; this is the standard way that inheritance tax is set for various assets.

As I was saying, these reforms get the balance right between supporting farms and businesses, fixing the public finances and funding public services. They reduce the inheritance tax advantages available to some owners of agricultural and business assets, but those assets will still be taxed at a much lower effective rate than most other assets—a £6 million estate owned by a couple, for example, could have an effective tax rate of just 1.2%, which can be paid, interest-free, over 10 years.

Those opposing these reforms in full will be voting for a status quo in which the very largest estates pay a lower average effective inheritance tax rate than the smallest estates—a status quo where the Exchequer sees £219 million in tax relieved from just 117 estates claiming APR, and £558 million in tax relieved from just 158 estates claiming BPR. That is not sustainable, and it is certainly not fair. I therefore commend clause 62, schedule 12 and Government amendments 24 to 29 to the Committee.

[The Chairman of Ways and Means (Ms Nusrat Ghani)]

I call the shadow Minister.

[Gareth Davies]

I wish to speak to amendments 3 to 23 in the name of my right hon. Friend the Member for Louth and Horncastle (Victoria Atkins). By now we all know what clause 62 and schedule 12 do: they would restrict agricultural property relief and business property relief to 100% of the first £1 million of qualifying assets and 50% thereafter—though I note that this legislation was written before the recent announcement, which I will obviously come on to. Members should be in no doubt that the Conservative party will fiercely oppose Labour’s family farm tax and family business tax in the Lobby today, just as we have since these policies were announced. We must first face the reality of the sheer number of Labour MPs intent on punishing those who dare to feed us, or who take a risk to build their own business.

Our amendments seek to mitigate at least some of the damage by removing the anti-forestalling measures that have purposely tied the hands of so many farmers and business owners across our country. The Chartered Institute of Taxation and many others have pointed out that these measures particularly trap more elderly farmers, who have been robbed of their ability to plan. The Government have said all along that they expect farmers and business owners to alter the ownership structure of their assets. I would be really interested to hear just how the Minister believes that elderly farmers, in particular those in the final few years of their life, should do that.

Before I turn to the other issues, I note that the amendment paper tells its own story: Government amendment after Government amendment, each one a U-turn and a rushed attempt to bury the incompetence, indifference and hostility that this Labour Government have shown to family farms, tenant farmers, rural communities and family businesses. I ask respectfully of the Minister, as my hon. Friend the Member for Gordon and Buchan (Harriet Cross) asked earlier, why it has taken the Treasury more than a year to admit that it got this wrong. Why have farmers been forced to leave their fields and bring their tractors to Whitehall, just to be heard?

I pay tribute to the shadow Secretary of State for Environment, Food and Rural Affairs, my right hon. Friend the Member for Louth and Horncastle, and to my hon. Friend the Member for Keighley and Ilkley (Robbie Moore), who gave this House five chances before today to vote against these changes. The Government had ample opportunity, but here we are. We know that their partial U-turn will not be enough. The Country Land and Business Association has been very clear that it will only limit the damage.

Many serious questions and concerns remain on the impact of clause 62, but I will highlight just three. First, from the very start the Government’s numbers have been, at best, questionable. The Treasury has disagreed with the CLA and others on how many farmers and businesses will actually be affected. Even after the partial U-turn, HMRC expects 1,100 estates to face larger inheritance tax bills in 2026-27, 185 of which will be claiming APR. Yet the experience of many Members, from speaking to farmers and businesses in our constituencies, and that of several industry bodies is that that figure is massively wide of the mark.

--- Later in debate ---

[Ruth Jones]

Absolutely; the hon. Member makes a point that I am going to come on to later.

Welsh farms are typically smaller than those in England, with 55% being less than 20 hectares, and 66% of Welsh farms are cattle and sheep farms situated on hilly or mountainous terrain, compared with just 12% in England, which also has a much higher concentration of arable farming. This leaves Welsh farms with the lowest average income of the four nations—£18,000 lower than in England. Welsh family farms are also a cultural bastion of the Welsh language, with almost half the people working on Welsh farms speaking Welsh as their first language—more than double the Welsh average.

While the Government’s changes to APR and BPR are likely to disproportionately benefit Welsh farmers, the diverse nature of farming across the four UK nations needs to be considered when making such significant changes. That is why the Welsh Affairs Committee continues to call for the Wales-specific impact assessment of the Government’s changes to inheritance tax that the hon. Member for Ceredigion Preseli (Ben Lake) just referenced. It is critical that those with the broadest shoulders pay their fair share of tax. That is why it is important that we close the inheritance tax loophole that allowed wealthy investors to purchase agricultural land as a way of avoiding tax.

Ensuring that the tax burden falls fairly relies on effective data, however. The Welsh Affairs Committee and I remain concerned about the availability and accuracy of the data used to justify the thresholds set for APR and BPR, particularly in regard to Wales. The Government have thus far been unable to provide any estimate of the number of Welsh farms that will be affected by these reforms to inheritance tax. Such data is critical when considering any potential impacts on the Welsh farming sector, given its greater financial precarity and reliance on low-income, family-run livestock farms. We cannot afford to be complacent. I hope that the Government will ensure that they take specific account of the unique cultural, environmental and economic circumstances of farming in Wales when making such significant policy decisions. I wholeheartedly support the changes to the APR and BPR as laid out in the Government’s amendment to schedule 12.

[The Chairman of Ways and Means (Ms Nusrat Ghani)]

I call the Liberal Democrat spokesperson.

--- Later in debate ---

[Charlie Maynard]

I thank my hon. Friend. [Interruption.] Would you like to intervene?

[The Chairman of Ways and Means (Ms Nusrat Ghani)]

Order. I have no desire to intervene on the hon. Member—“Would the hon. Member like to intervene?”

[Charlie Maynard]

My apologies, Ms Ghani.